IEEPA Tariff Refund Guide 2026: What DHL Shippers Need to Know

What Happened

On February 20, 2026, the U.S. Supreme Court ruled 6-3 that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceeded presidential authority and were unconstitutional. As a result, IEEPA tariffs stopped applying to U.S.-bound shipments as of February 24, 2026 at 12:00 a.m. EST.

Note: Other tariff programs—including Section 301 and Section 232—remain in effect and are not affected by this ruling. The administration has also sought to maintain some tariffs using alternative legal authorities such as Section 122, so the broader tariff environment continues to evolve.

When Did Refunds Start?

CBP launched the CAPE (Consolidated Administration and Processing of Entries) system and began accepting Phase 1 refund claims on April 20, 2026.

Phase 1 scope:

• Formal entries (over $2,500 or requiring other government agencies): duties paid between March 22, 2025 and February 24, 2026
• Informal entries (under $2,500, filed electronically): duties paid between January 30, 2026 and February 24, 2026

Important: Phase 1 is primarily focused on formal entries (over $2,500). Refund processing for small parcels (informal entries under $2,500) is expected to expand in Phase 2. The scope for low-value shipments is currently limited.

The following entries are excluded from Phase 1:

• Entries subject to Antidumping/Countervailing Duties (AD/CVD)
• Entries flagged for reconciliation
• Certain already-liquidated and finalized entries

If DHL Was Your IOR: Automatic Filing

If DHL acted as the Importer of Record (IOR) for your shipments, DHL states that it will automatically file refund claims with CBP on eligible Phase 1 entries and return the funds to the party that originally paid the duties once CBP issues the refund.

That said, we recommend proactively checking your own records rather than waiting passively. Here's how to verify:

1. Log into DHL MyBill
2. Pull up duty invoices from the eligible period (March 2025–February 2026)
3. Look for credit entries (negative line items) in the duties and fees section
4. Open the duty invoice and confirm whether DHL is listed as the IOR

CBP is expected to take approximately 60–90 days to process refunds after claims are submitted—don't expect immediate results.

If You Are the IOR: You Must File Through CAPE

If DHL provided customs brokerage only and your company was the IOR, you must file your own refund claim through CBP's ACE portal. Even if DHL filed the customs entry on your behalf, if your company is listed as the IOR, automatic filing does not apply to you.

Critical step many importers miss: CBP only issues refunds via ACH bank transfer. No checks will be issued. You must register an ACH refund account in the ACE portal before you can receive any refund. Without this registration, CBP cannot pay you even if your claim is approved.

Steps:

1. Access the CBP ACE Secure Data Portal
2. Create an ACE account if you don't have one
3. Register your ACH refund bank account
4. Prepare and upload a CAPE Declaration CSV file
5. Include entry numbers, duty amounts, and payment dates

Claims can be filed by the IOR directly or by a licensed customs broker. A single CAPE Declaration can cover up to 9,999 entries.

Latest Status as of June 2026

On May 29, 2026, CBP filed a motion with the U.S. Court of International Trade (CIT) stating that it does not believe it has legal authority to refund duties on entries that have already been liquidated and finalized—and signaled its intent to appeal the universal injunction.

For importers with a large number of already-liquidated entries, the outcome of this legal dispute will directly affect whether refunds are ultimately issued. LogiWatch will continue monitoring CBP and CIT developments.

Summary: What to Do Now

| Situation | Action | |-----------|--------| | DHL was your IOR | Check DHL MyBill for credits. Allow 60–90 days for processing | | Your company was the IOR | Register ACH account in ACE → file CAPE Declaration | | Shipments under $2,500 | Wait for Phase 2 guidance | | Already-liquidated entries | Monitor CBP/CIT legal developments |

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Disclaimer: This article reflects conditions as of June 2026. The legal and administrative situation around IEEPA refunds is still evolving. Always verify with CBP official sources and LogiWatch updates. This article does not constitute legal or tax advice.